Issue of reassessment notice

Sanction for Notice
Section 151 of the Act deals with the sanction for issue of notice. Section 151 reads as follows:  “151. (1) In a case where an assessment under sub Section (3) of Section 143 or Section 147 has been
made for the relevant assessment year, no notice shall be issued under Section 148 by an Assessing
Officer, who is below the rank of Assistant Commissioner or Deputy Commissioner, unless the Joint Commissioner is satisfied on the reasons recorded by such Assessing Officer that it is a fit case for the issue of such notice: Provided that, after the expiry of four years from the end of the relevant assessment year, no such notice shall be issued unless the Chief  Commissioner or Commissioner is satisfied, on the reasons recorded by the Assessing Officer aforesaid, that it is a fit case for the issue of such notice. (2) In a case other than a case falling under subsection (1), no notice shall be issued under Section 148 by an Assessing Officer, who is below the rank of Joint Commissioner, after the expiry of four years from the end of the relevant assessment year, unless the Joint Commissioner is satisfied, on the reasons recorded by such Assessing Officer, that it is a fit case for the issue of such notice. Explanation — For the removal of doubts, it is hereby declared that the Joint Commissioner,
the Commissioner or the Chief Commissioner,  as the case may be, being satisfied on the reasons
recorded by the Assessing Officer about fitness of a case for the issue of notice under Section 148,
need not issue such notice himself.”

Aggreed with SATISH